Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Condonation of delay in filing appeal before the appellate authority - The Appellate Authority also considered the extension of limitation granted by the Hon'ble Supreme Court due to the pandemic situation, which saved the limitation between 15.03.2020 and 28.02.2022. The Supreme Court directed that appeals could be filed within ninety days from 01.03.2022, which means an appeal could have been filed on or before 29.05.2022. However, the petitioner filed the appeal on 13.04.2023, after 289 days from the expiration of even the extended limitation period. - The High Court dismissed the writ petition.
Condonation of delay in filing appeal before the appellate authority - The Appellate Authority also considered the extension of limitation granted by the Hon'ble Supreme Court due to the pandemic situation, which saved the limitation between 15.03.2020 and 28.02.2022. The Supreme Court directed that appeals could be filed within ninety days from 01.03.2022, which means an appeal could have been filed on or before 29.05.2022. However, the petitioner filed the appeal on 13.04.2023, after 289 days from the expiration of even the extended limitation period. - The High Court dismissed the writ petition.
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TaxTMI 
TaxTMI 
